I've driven on London twice in my life, so these won't affect me directly. However if London get away with this I reckon most other councils will see it as an opportunity to up their own PCN's, so I've entered in my tuppence-worth.

It took me longer to complete their nonsense equal opportunities box ticking at the end than to complete the questionnaire though.

Don't know why they bother with a consultation. All consulted will say no thanks and they'll just up the charges anyway.

Consultation will be a legal requirement in the London process to set penalty charges, so they're going through the box-ticking exercise. Then once all the boxes are ticked the penalties are increased. It's a total scam as no regard whatsoever will be taken of the consultation returns.

I would be more interested if the consultation was to actually look to see if the present system is working or if alternatives exist.

Within the council forum, by far the most prolific authorities we see are London councils.Seemingly chucking out PCNs left right and centre while earning a small fortune from them.

So has this industrial process resulted in fewer offenders and less problems in parking, congestion etc.Or is it simply a money making exercise with no thought to the traffic management process it is supposed to be aiding.

We know it's all about the cash, and many others suspect so. You are right about box-ticking though. Even if everyone responding to the consultation was against this increase, they'd still up it. Ca£h is king!

If anyone wants to comment on the public consultation you have until 10 November to do so.

Here's my submission. The numbers below are what TfL asked the public to comment on.

1. Do you believe that there are other, alternative options to increase compliance with the red route network and congestion charging zone? If so, please record your thoughts below.

Clear signage

Clear signage and greater driver awareness of the rules would, I believe, have a bigger impact to deter violations of the rules. Regarding clear signage you could, for example, have advanced warning signs of a box junction ahead with a camera sign to show that it is monitored (just as motorists have clear warnings of speed cameras). There is a precedent for how this could assist drivers from blocking a box junction. On 12th June 2013 the Panorama programme on BBC tv broadcast a programme about drivers who were getting caught in large numbers on a particular box junction. During the programme the presenter put up signs to warn motorists about the box junction and lo and behold the number of motorists getting stuck on the box junction fell dramatical. Also, when approaching a box junction there can be pressure from behind from other drivers who would not be aware that there is a box junction ahead and so would tend to get annoyed when drivers in front stop for no apparent reason.I think a distinction ought to be made between box junctions where there is no advance warning signs and red routes, bus lanes and congestion charging zone where there is clear signage. If you decide NOT to put warning signs in advance of box junctions then I believe your non-action on this point will contribute to the congestion problem and I think drivers should accordingly be treated much more leniently for this offence than if they commit other violations.

Driver Awareness

Not all drivers are aware of why the rules exist and the financial penalties involved for contraventions. If they were fully aware and the financial penalties they might drive more carefully. I explain below how one significant group of drivers could be certain to be made aware. In respect of driver awareness, I noticed from your graphs that there was a significant peak in PCNs in 2013/14. Has any analysis been done as to why that might have happened? If not then let me hazard a guess. Uber started their operations in London in June 2012 so by 2013/14 they would have been recruiting drivers in large numbers. A lot of these drivers would have been new to the hustle and bustle of being a cab driver in London so I expect a lot of them would have been in the statistics for 2013/14 and beyond – you have access to this information so you might want to check it out. There was another significant spike in 2016/17 so maybe Uber was on another recruitment drive then. I expect a lot of these new naïve drivers were so busy trying to whiz around to do as many jobs as possible that they get tired doing too many hours and they lost their concentration.

I would suggest that a very effective way to increase driver awareness for those who spend most of their working lives driving around London would be to make PCN liability knowledge a mandatory part of the requirement to obtain a Private Hire or Taxi licence.

Repeat Offenders

Your document makes the point that repeat offenders are a large part of the problem. It would be interesting to know how you classified repeat offenders – was it by the registration number of the vehicle or by the name of the driver and did it include the foreign embassies who are notorious for not paying PCNs. If the latter make up a part of the repeat offenders then obviously putting up the cost of PCNs will make no difference to this group of offenders.

Some of the repeat offenders may well be quite wealthy individuals so don’t really care about the cost of PCNs. Other repeat offenders might just be careless drivers. So, with repeat offenders I would suggest you try a sliding scale of charges – for the first offence there would be a charge of £x; for a 2nd offence the charge would be double £x; for a 3rd offence the charge would be triple £x and so on. To be fair to those motorists who only get one PCN in say a 12 month period (due to perhaps making a genuine mistake) perhaps the starting point for a first PCN should be reduced to £100. I would say that the one-size-fits-all proposal to increase the PCN to £160 is a blunt instrument and that my sliding scale suggestion is fairer and would have a greater impact as a deterrent

2. Would the increase in the value of a PCN cause you any particular difficulties or hardship, or unfairly penalise any particular group of road users? If so, please record your thoughts below.

Yes, I am a private hire driver and even at the present discount level of £65 in can take away all the profit for a day's work. The consultation paper talks about inflation but it should be borne in mind that because of the present economic situation most people's incomes have gone down in real terms in recent years so therefore any increase as proposed would just simply increase hardship and not act as a greater deterrent in the way predicted. The current rate is already overly draconian and so increasing it would not have the desired effect. Imagine, dear reader, if you got a PCN to or from the way to work – you’d probably wished you stayed home and thrown a sickie.

3. If you have any other concerns or comments about our proposals, please record them below.

There are some false and unsubstantiated statements in your Overview and Impact Assessment documents. For example, in the Impact Assessment document on page 6, 1.2 1 it says, “The prospect of receiving a PCN is not as significant a deterrent against poor driving behaviour as it has been in the past. This is demonstrated by the year on year increases in the number of recorded contraventions.” It is wrong to say that there has been year on year increases because your graphs show a significant fall from 2013/14 to 2014/15. And is it about poor driving or is it more to do with lack of driver awareness and lack of signage at box junctions.

Also, where’s the evidence to show that raising the PCN charge by over 22% would make any significant difference to the amount of PCNs issued. Your documents are simply filled with vague speculation and assumptions.You offer no evidence to show if the previous increases in the PCN charge in previous years had the effect of making things run more smoothly.

Of course, a major concern, is the perception that the proposal is really just about raising extra revenue (to perhaps replace the gap left by the withdrawal of central government funding - I just did an internet search to see how TfL is funded and I came across this statement from a TfL website: “Grants make up 23% of our funding in 2017/18 (£2.35bn) and are received from central and local government. The main sources are:• The DfT general grant which partly covers our operating costs. 2017/18 is the last year we will receive this grant”

I expect there will be those that regard your documented proposals as just a load of waffle and window dressing as an excuse to simply extract more money from the already hard-pressed motorists to plug the gap in TfL’s finances. On the front page of your Overview document it says, “We invest every penny we raise from issuing PCNs back into London’s road and public transport network”. That would imply that the money from PCNs is ringfenced. I wanted to check this so I clicked on the TfL group statement of account links on the bottom of page 9 of the Impact Statement and all I got was this:404 Not Found• Code: NoSuchKey• Message: The specified key does not exist.• Key: tfl-group-statement-of-accounts-for-201617-27-june.pdf• RequestId: C8EF0B947ACE52B3• HostId: A17QiSsNcB6UAq+ohZBt22O8l4GyQCpnCeOKX/kSWF6GljouYe+HyWiXx2nWLjGXV5lsAJKEw/Q=

TfL revenues and Investment

The whole tenor of the justification for putting up the PCN charge seems to be contradictory. It is stated (in the Impact Assessment document under 2.2 Economic Impacts), “Congestion on London’s roads costs in excess of £2b each year and is a huge hinderance to businesses, commuters and the freight industry.” This, in part, is used as a justification for increasing the PCN to £160 as a means whereby it is expected that motorists will commit less breaches of the rules thereby reducing the cost to business of congestion.” And then (in the same section) it says, “The economic impacts of the proposed changes are assessed with reference to………The effects on TfL revenue and hence investment in transport improvements elsewhere on the network”. So, in other words, TfL always need plenty of revenue from PCNs for their funding requirements. Strange sort of logic, isn’t it? Just imagine, for one idealised moment, that no one committed any offence so that TfL was not able to issue a single PCN. Don’t worry, in this idealised situation I guess you could somehow turn to the business community and say, Look, you’re no longer suffering from so much congestion because everyone is behaving themselves BUT we know that you’re a lot better off now due to our efforts so we will need to increase your business rates to maintain this more serene environment – a “legalised” protection racket some might say.

Economic ImpactsConsideration of the General Equality Duty

On page 11 of the Impact Assessment document under 2.3.1 Consideration of the general Equality duty – Introduction it says, “……In line with best practice TfL also considers the needs of groups who also have the potential to be socially excluded, namely: people on low incomes…….”. Well, there are plenty of drivers (such as private hire drivers) who are on low incomes – so low that they have to get a top up to their incomes with working families tax credit or universal credit.” So, if TfL considers the needs of people on low incomes does this mean that a PCN for this group of people will be at a lower rate? If not this then what? And/or would it mean time to pay a PCN (i.e. so much per month). In the past when I’ve tried asking for this I’ve been meant with, If you don’t pay the full amount by the due date the PCN will be increased by 50%. It doesn’t seem to matter that someone might be struggling to pay the rent or put food on the table. How callous is that!!!And then on the next page (12) 2.3.2 Overall conclusions it unbelievably states, “An equalities impact assessment was undertaken and found that there is no evidence that an increase in the PCN value for the Congestion Charge or TLRN contraventions would disproportionately affect any of the equality target groups. In view of the above that is plainly utter nonsense.

How will motorists know about the increase in the PCN charge?

This proposed increase will only be noticed by repeat offenders and those who had received a PCN relatively recently before the increase. It will not register with the majority of all other motorists who only get the occasional PCN every now and then? I suspect most motorists who get a PCN just pay up within the discount period either because they don’t have the time to contest it (even if there is a valid reason to do so) and/or don’t have the knowledge/confidence to do so. Therefore, for those motorists who do pay up during the discounted period it will mean paying £80 rather than £65. Do you honestly think that as motorists drive around they will have the thought of that extra £15 uppermost in their mind – would you? And therefore, increasing the cost of the PCN will not have any significant impact on driver behaviour – just as it hasn’t done in the past.

Finally, I would just like to say a few words about:The Appeals Process

If you are going to reform the PCN amount then, to be fair, the appeals process ought to be reformed. At present the motorist can make an initial appeal to TfL (if he/she has time) within a certain time limit. If TfL refuses that appeal the driver still has the same time limit available (from the date of the refusal) to pay at the discounted rate. BUT although the driver has the right to then appeal to the independent tribunal (PATAS) the driver then runs the risk of losing the option to pay at the discounted rate should the driver lose his appeal at PATAS. This is obviously a disincentive to make an appeal to PATAS. Only a relatively small minority have the time/confidence to make an appeal to PATAS so it is not fair that the driver should lose his right to the discounted amount of the PCN if he/she loses at PATAS.If the driver wins at PATAS it means that the PCN should not have been issued in the first place and it also means that the appeal should have been allowed by TfL at the initial appeal. Therefore, if the motorist is successful at PATAS it means that he/she has had to go to a lot of trouble to prove their innocence (from a position of guilt). Therefore, to be even-handed the risk should not just be on the motorist for taking the appeal to PATAS but there should also be some financial risk on TfL for refusing the initial appeal. Therefore, an amount equal to the discount amount of the PCN should be payable to the motorist if it is paid within the same time period that is allowed for a motorist to pay TfL at the discounted rate. If it isn’t paid within this time period then the full amount of the PCN should be paid to the motorist and if it still isn’t paid during a further time period then the amount payable to the motorist should be increased by 50%. In other words, if the motorist is successful at PATAS the same rules should apply to TfL as apply to the motorist. Just as the threat of a PCN is a deterrent to an errant motorist then a financial penalty should be a deterrent for issuing and then not cancelling an unfair PCN.

Well done !Of course as it is consultation they can completely ignore everything submitted, and in truth this consultation is a box-ticking exercise so they can say they have done it. The truth of the matter is that the comments made in this submission about TfL funding is the real issue. Where is the buses subsidy to come from now that government funding has been reduced ? Yes, the motorist. I personally think TfL is a rather immoral organisation, and this really does confirm that. No matter how trivial the offence a PCN is issued. This cannot be on any other basis other than getting the dosh in. All other councils in Great Britain seem to manage OK on half the TfL penalty. What is sauce for the goose is sauce for the gander.